The U.S. IRS has published an updated practice unit, How to Allocate and Apportion Research and Experimental (R&E) Expenses for Tax Years Beginning Before 1/1/2020. The process overview of the practice unit includes the following:

NOTE: Treas. Reg. 1.861-17 regarding the allocation and apportionment of R&E expenditures was significantly revised by TD 9922 in November 2020. The regula…